[ga] Re: [GTLD Registries List] FW: .BIZ Transfer Policy

[Jeff Williams <jwkckid1@ix.netcom.com>]

Jeff and all assembly members or other interested parties.

  First let me thank you Jeff for your response.  It was quite interesting
to say the least.  However I must take exception with you statement
characterizing my stated position and the position of our [INEGroup]
members.  You are incorrect that I or our members have "Jumped"
to any conclusions.  I certainly have not, and I know of no INEGRoup
member that has to date either.  Secondly, I nor any of our members
have reached any conclusions on what would be the best solution to
the problem of Domain Name Transfers, as it seems for the time being,
Nuelevel has.  So I hope that you are now clear or straightened out
a bit better on my and our members current thoughts on the Domain Name
Transfer problem.

  It is also very interesting and worthy of note, that Nuelevels stated
position on Domain name Transfers is somewhat different that
what you are espousing in your response to me (See below).
First you state that Nuelevels "Official" position is, and I quote
from below:
"It is NeuLevel's belief that there is currently no acceptable method for
 transferring domain names in the existing gTLD space that accomplishes the
 goal of portability of domain names while at the same time preventing
abuses such as "slamming."  As most of you are aware, and as has
been extensively documented, there are significant problems in
the .com, .net and .org TLD space with how transfers of domain
names occur, not the least of which is > the challenge of establishing
apparent authority."
=======  End of quote from "Official" Nuelevel Position =====

  Than here in your response you state, that Nuelevel is, and has
been working with the Registrar and Registry community to
come up with a solution to the Domain Name Transfer problem.

  These two positions seem to be quite opposed to each other
with respect to actual interest in aiding in solving the problem.
As such, it would seem that Nuelevel is more interested in
their self interest with maintaining the original registrant and
his/her Domain Name, irrespective of that registrant perhaps
wishing to transfer that Domain Name to another Registrar,
or even possibly another .BIZ registry.  Of course you know
that there is more than one .BIZ registry...

  Although I can see clearly that not wishing to allow for a
Nuelevel Registrant to be able to transfer his/her domain
is enlightened self interest for Nuelevel, it does not provide
for the Registrant the flexibility he/she has under the current
ICANN Registrar agreements/contracts...  So the creation
of confusion on the consumer would seem to be at least
in part done by Nuelevel for .BIZ registrants or potential
registrants.

  However we [INEGroup], some of which are .BIZ registrants,
do agree that much confusion is apparent or present given the
poor Registrar Contract that ICANN edicted upon the consumers/
stakeholders without their consent or consideration.  So addressing
the confusion of the consumer/stakeholder would be in order.

  As to to Nuelevels "Official" position on the aspect of Domain
Name Transfers with respect to "Slamming" as being one of the
more concerning problems in transfers of domain names, we
don't see such as a main issue.  Rather we see the ability
of the loosing registrar or registry for a Domain Name
being transferred having the ability to hold hostage the
Domain Name holder and the opportunity for Domain
Name Hijacking during the current transfer process,
as being much more concerning as has been noted on several
public forums discussing these DNS related issues...

  You also stated in your response here that:
"2)  It is not in the interest of any new Registry, including NeuLevel, to
inhibit portability.  To be blunt, transfers are a revenue event for the
Registry (because an additional term must be bought with every transfer), so
it is very much in a Registry's interest to see that the transfer process is
as easy as possible."

  I would have to say that this statement is only half true.  It is true
to the extent that the receiving registrar or registry will receive
a financial benefit from making and receiving a transfer that would
exceed the transfer fee that the loosing registry would realize.
It is not true that any and all transfers benefit all registrars or
registries on necessarily and equal basis.  And again in this
response, you differ significantly from your Nuelevel's
"Official" position...

  Neuman, Jeff wrote:

> Jeff,
>
> Thanks for your e-mail.  You are certainly entitled to your opinion on the
> subject, but perhaps before jumping to the conclusion that you already have,
> please consider the following:
>
> 1)  NeuLevel has every interest in finding a workable solution to the
> problems associated with transfers between Registrars.   NeuLevel, a
> subsidiary or NeuStar, has since the very beginning supported the Registrars
> position in doing everything possible to enhance the portability of domain
> names.  In fact, NeuStar has a long history of enhancing portability of
> telephone numbers for all of North America.  For example, because of
> NeuStar, all United States consumers can switch local telephone companies
> without having to change their phone numbers because we maintain the Local
> Number Portability database.  The parallels between the telephone industry
> and domain names are striking, and NeuStar intends to apply the same
> philosophies to the Internet space.
>
> 2)  It is not in the interest of any new Registry, including NeuLevel, to
> inhibit portability.  To be blunt, transfers are a revenue event for the
> Registry (because an additional term must be bought with every transfer), so
> it is very much in a Registry's interest to see that the transfer process is
> as easy as possible.  That being said, we do not want to allow the transfers
> to take place until the proper secure systems are in place, and the ultimate
> consumer is protected.
>
> 3)  We believe the mess in .com, .net and .org has taken way too long to
> resolve and often the consumer is being left out of the debate.  With the
> new method that NeuLevel is proposing to be adopted, consumers will be able
> to easily transfer their domain names by giving their "auth-info" tokens to
> the "gaining registrars" and see their transfers take place immediately --
> No e-mails from the losing registrar, no auto-nacks, no games -- no hassle
> to the consumer.  If a registrant presents a valid token to the gaining
> registrar when a transfer is requested, the Registry knows that the transfer
> has been authorized by the Registrant.  There will be no waiting periods and
> thus, no room for a losing registrar to "game" the system.
>
> 4)  Before this can happen, however, registrars and registrants must be
> educated on how to generate a token, how to maintain the security of a
> token, and how to recover a lost token, through the EPP Protocol used by the
> "thick registries."  This takes time.  We are aggressively engaging in such
> an educational campaign now and as soon as the Registrars and Registrants
> can be educated, you will see a far more superior and secure transfer
> mechanism than anything that currently exists.
>
> Thanks.
>
> Jeffrey J. Neuman, Esq.
> Director, Policy and Intellectual Property
> NeuLevel, Inc.
> Loudoun Tech Center
> 46000 Center Oak Plaza
> Building X
> Sterling, VA 20166
> e-mail: Jeff.Neuman@NeuLevel.biz
>
> -----Original Message-----
> From: Jeff Williams [mailto:jwkckid1@ix.netcom.com]
> Sent: Thursday, January 17, 2002 4:45 PM
> To: Neuman, Jeff
> Cc: 'gtld@gtldregistries.org'; 'michael@Palage.com'; General Assembly of
> the DNSO
> Subject: Re: [GTLD Registries List] FW: .BIZ Transfer Policy
>
> Jeff and all,
>
>   I am afraid that I would have to disagree with Richards contention
> here with respect to Transfer of Domain names.  His long winded
> explanation after stating his and it seems Nuelevels position on this
> issue is also a bit suspicious in and of itself to boot.  In that Richard
> is a sales person and therefore is predisposed to "Sell" this position
> whether of not it has merit, also looks very suspicious.
>
>   Therefore I can only read this Nuelevel position as one that
> strongly indicates that Nuelevel is not interested in looking or
> assisting in finding a workable solution to the many Transfer
> problems and poor practices that have been broadly reported
> and have become a concern of fairly large proportions.  In addition
> this Nuelevel position seems to be one of protecting your own
> .BIZ registrations and registrants whether or not they would like
> to move to a different registrar.
>
> Neuman, Jeff wrote:
>
> > FYI - This is the note that NeuLevel sent out to the Registrars earlier
> > today regarding transfers in the .BIZ domain.
> >
> > Jeffrey J. Neuman, Esq.
> > Director, Policy and Intellectual Property
> > NeuLevel, Inc.
> > Loudoun Tech Center
> > 46000 Center Oak Plaza
> > Building X
> > Sterling, VA 20166
> > e-mail: Jeff.Neuman@NeuLevel.biz
> >
> >
> ****************************************************************************
> > *****************************************
> >
> > Dear Registrar Partner,
> >
> > We have recently received numerous questions and comments from registrars
> on
> > the issue of domain transfers between registrars, and we want to begin a
> > dialogue with you on the transfer-related challenges facing our industry.
> >
> > It is NeuLevel's belief that there is currently no acceptable method for
> > transferring domain names in the existing gTLD space that accomplishes the
> > goal of portability of domain names while at the same time preventing
> abuses
> > such as "slamming."  As most of you are aware, and as has been extensively
> > documented, there are significant problems in the .com, .net and .org TLD
> > space with how transfers of domain names occur, not the least of which is
> > the challenge of establishing apparent authority.  The current situation
> is
> > not only confusing for registrars, but also to the ultimate consumer.
> >
> > We also understand that many registrars are just now becoming familiar
> with
> > the capabilities and functionality of the "auth-info" tokens provided by
> the
> > so-called "thick registries" including .biz and .info.  However, overall
> > knowledge of the thick registry transfer process, particularly at the
> > Registrant level, is still minimal or non-existent.
> >
> > Some of the problems that have come to our attention include (a) that some
> > Registrars are generating blanket (common) tokens for all domain name
> > registrants; (b) other registrars are not providing tokens to their
> > customers at all; (c) registrants are neither requesting tokens nor do
> they
> > have an adequate understanding about the need or use for tokens.  Finally,
> > there do not yet exist secure and efficient systems for token retrieval
> > (re-issuance) in cases where a token is lost or stolen.
> >
> > The net result is that few unique, secure and valid tokens are getting
> into
> > the hands of registrants, and hence to potential gaining Registrars.
> While
> > this is not the result of bad faith or bad practice by Registrars, it is
> > currently causing a gap in the education of the Registrar community and
> with
> > our ultimate consumers, the Registrants.  The industry and end-user
> > population have simply not been educated in the proper use of "auth-info"
> > tokens.   This is the fault and responsibility of NeuLevel as much as
> > anyone.  We feel that it is both our responsibility and obligation to
> ensure
> > that systems for the proper issue, storage and processing of tokens are
> > institutionalized within the industry.
> >
> > We do not believe there is currently a working transfer model in the gTLD
> > industry.  If we implement .BIZ transfers now we expect we would
> contribute
> > to industry problems rather than fixing them.  Therefore, we intend to
> > freeze .BIZ transfers for a period of 30 to 60 days and engage in a
> program
> > of channel/user education regarding transfers with tokens. In this program
> > we will work with you to create systems and awareness for the issue,
> storage
> > and processing of secure, unique, valid tokens.  We do not believe this is
> > an insurmountable task.  We are at fault for not initiating it sooner, and
> > we want to advance this dialogue with you for the betterment of our
> industry
> > practices and for the enhancement of the end-user experience.
> >
> > In addition, during this period, we also intend to discuss with each of
> you
> > the merits and flaws of a system that recognizes a five (5) day ACK/NACK
> in
> > a system that already provides for reliable, authorized transfers by using
> a
> > valid token.  With your collaboration we will look to stimulating industry
> > debate on the merits of instantaneous transfer (in the presence of a valid
> > token).  We believe this is an achievable and desirable position, when we
> > have all institutionalized the proper management of tokens.
> >
> > I will be available to discuss this as will your Registrar Relations
> Account
> > Executive.  Thank you in advance for your cooperation and contribution to
> > this dialogue.  If you have any immediate reactions, please feel free to
> > respond to this email and we'll begin collecting and reviewing your
> > feedback.
> >
> > Sincerely,
> >
> > Richard Tindal
> > Vice President, Sales and Channel Relationships
> > NeuLevel, Inc.
> > 46000 Center Oak Plaza
> > Sterling, VA 20166 USA
> > richard.tindal@neulevel.biz
> >
> > ---------
> > Participants on the gTLD Registry Constituency public mailing list are
> requested to not cross-post messages.
>
> Regards,
> --
> Jeffrey A. Williams
> Spokesman for INEGroup - (Over 121k members/stakeholdes strong!)
> CEO/DIR. Internet Network Eng/SR. Java/CORBA Development Eng.
> Information Network Eng. Group. INEG. INC.
> E-Mail jwkckid1@ix.netcom.com
> Contact Number:  972-244-3801 or 214-244-4827
> Address: 5 East Kirkwood Blvd. Grapevine Texas 75208

Regards,
--
Jeffrey A. Williams
Spokesman for INEGroup - (Over 121k members/stakeholdes strong!)
CEO/DIR. Internet Network Eng/SR. Java/CORBA Development Eng.
Information Network Eng. Group. INEG. INC.
E-Mail jwkckid1@ix.netcom.com
Contact Number:  972-244-3801 or 214-244-4827
Address: 5 East Kirkwood Blvd. Grapevine Texas 75208


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